Admin & Program Owner Privacy Policy

Draft data privacy policy for administrative authority and/or program owner

Scope

This document is a sample data privacy and protection policy for the administrative authority and/or the program owner to pick up and replicate on their user-facing web pages. Entities using this document may make modifications as relevant to the context in which they are using this document.

This document is a draft for reference and does not have any legal effect in and of itself.

• eGovernments Foundation does not guarantee that this document will correctly represent all relevant laws or legal obligations, as these can vary across jurisdiction and time.

• eGovernments Foundation does not guarantee that the use of this draft, with or without modifications, will cover any or all legal obligations of a specific entity in a specific jurisdiction.

• Any entity or individual that uses this draft, with or without modifications, does so at their own discretion, and at their own risk.

• By using the draft policy provided, you acknowledge and agree that:

• The draft policy is provided for informational purposes only and does not constitute legal advice.

• The draft policy is a general template and may not be suitable for your specific needs or circumstances. It is your responsibility to review and modify the draft policy to meet your requirements.

• We make no representations or warranties, express or implied, regarding the accuracy, completeness, or reliability of the draft policy. We do not guarantee that the draft policy is up-to-date or compliant with current laws or regulations.

• You assume all risks and liabilities associated with the use of the draft policy. We shall not be held liable for any direct, indirect, incidental, consequential, or special damages or losses arising from the use or reliance on the draft policy.

• We recommend consulting with a qualified legal professional to obtain advice tailored to your specific circumstances before implementing any policy based on the draft provided.

• By using the draft policy, you agree to release and discharge us from any claims, demands, liabilities, actions, or causes of action arising out of or in connection with the use of the draft policy."

• It is crucial to seek legal advice to ensure that this policy meets your specific requirements and is enforceable in your jurisdiction.

Data Privacy Policy For Admin Authority &/or Program Owner

<PROGRAM NAME> (“we” or “us” or “our”) respects the privacy of our users (“user” or “you” also referred to as ‘your’). Hence, we maintain the highest standards for secure activities, user information/data privacy and security.

<PROGRAM NAME> is a collaboration between <PARTNER(S) NAME(S)> and eGovernments Foundation. It is powered by DIGIT, which is an open-source software platform developed by eGovernments Foundation.

This privacy policy describes and determines how we deal with your personal and usage information in accordance with the applicable laws of India.

<PROGRAM NAME> refers to the services being provided through <PROGRAM NAME> website, mobile App, <OTHER CHANNELS AS RELEVANT>.

Through <PROGRAM NAME>, you can access and avail of services offered by <STATE OR ULB NAME> Government departments, Central Government department, Local bodies & their agencies and corporate/private bodies (utility services).

You can use <PROGRAM NAME> website/application/services in different ways such as service discovery, availing services, registering grievances, and so on.

1. OBJECTIVE OF THE POLICY

The purpose of this policy is to maintain the privacy of and protect the personal information of users, employees, contractors, vendors, interns, associates, and partners of <PROGRAM NAME>. The <PROGRAM NAME> ensures compliance with laws and regulations applicable (partner to insert a list of laws they have to comply with ) to <PROGRAM NAME>.

2. ADHERENCE TO DATA PRIVACY PRINCIPLES

We adhere to the principles of accountability, transparency, purposeful and proportional collection, usage, storage and disclosure of personal data (“PD”)[1].

3. WHAT DATA DO WE COLLECT? OR WHAT IS ‘DATA’ UNDER THIS ‘PROGRAM’?

We collect and/or access, store, process, use, and share information/data (“data”) to improve and provide better services to you. We collect and process PII such as your first name, last name, parent’s / guardian’s name, address, email address, telephone number, age, gender, and identification documents. We may collect your educational, demographic, location, device and other similar information.

We collect information such as Internet Protocol (IP) addresses, domain name, browser type, Operating System, Date and Time of the visit, pages visited, IMEI/IMSI number, device ID, location information, language settings, handset make & model etc. However, no attempt is made to link these with the true identity of individuals visiting <PROGRAM NAME> app, website, Whatsapp Chatbot etc.

The information collected by us shall depend on the services being used by you and may vary from time to time, which will be informed through changes in this policy.

We also collect, store, process, and share information pertaining to employees of local government or other government agencies. Specific information can include name, age, gender, details of spouse or dependents, address, administrative details such as employee ID or other reference number, as well as information on bank accounts (used for processing salaries or pensions). As employers, local governments may be required to maintain certain information on their employees and pensioners for tax purposes, such as PAN numbers; this information may also be recorded and shared.

We derive, store, process, and share transactional data, which describes the progress of any ongoing task (e.g. any service requested by a resident) through the systems of the local government or other government agency. This can include information about the specific role to whom a given task is assigned (or with whom it is pending), the amount of time elapsed on processing / completing a given request (or task / sub-part thereof), and whether this task has been completed within the benchmark or designated amount of time. It can also include details about the channel through which a particular request was received, such as the ULB counter, service centre, website, helpline, mobile app, chatbot, etc.

We derive, store, process, and share aggregated data. These aggregates are derived from the transactional data. This includes data such as aggregate or cumulative revenue collection, aggregate or cumulative number of service requests, percentage of requests resolved within the benchmark time period, etc. The above data may be further analysed and presented in terms of the type of collection, request, or complaint, the channel through which it was received, etc.

We may collect, store, process, and share telemetry data, which studies how much time is spent on a given screen or field in a workflow/user interface (UI). Such data is normally processed and shared in aggregate, and will not be used to identify specific individuals. In the event that specific individuals are sought to be identified, such as for user research, their consent will be sought for the further processing or sharing of their data.

4. HOW DO WE COLLECT THIS DATA?

We collect data directly from you (when you use our services) as and when you register and login into the app/website. We may also collect data from Union, State, and Local governments, including their agents/employees as well as receive data that is available openly for public use.

5. HOW DO WE STORE THIS DATA?

Your data is stored in a secure manner. <PROGRAM NAME> is powered by the DIGIT platform, which has embedded privacy settings (such as encryption), which do not allow your data to be visible to anyone, except persons who are authorised to do so by virtue of their official role. Unless indicated otherwise, this data will be retained for a minimum period of <AS PER UNION / STATE / ULB LAWS> and a maximum period of <AS PER UNION / STATE / ULB LAWS>. You can review and edit your data, as well as delete your data from the app/website by following the procedures <AS PER UNION / STATE / ULB LAWS>.

You may delete your account at any time you wish. In case of deletion, we will remove all your PD from the system, so that it is not visible and/or accessible from any regular operation. However, the PD may be retained in an encrypted manner for the purpose of legal requirements/compliances <AS PER UNION / STATE / ULB LAWS> from the date of deletion/termination.

After deletion, in case you wish to recreate your profile, the same is permissible and none of the previously captured information will be populated automatically. You need to register as a fresh user.

If you simply delete/remove the application from your mobile device but do not delete your profile or unregister yourself from the app/website, you shall continue to be a registered user of the app and we shall continue to send you all communications that you have opted for unless and until you opt-out of such communications, or <AS PER UNION / STATE / ULB LAW>.

In case you surrender/disconnect your <PROGRAM NAME> registered mobile number it is recommended to delete your profile or unregister yourself from the application also.

Data Security Measures

With respect to such data, we ensure the following safeguards:

• Define roles for our employees, and grant access only to such data as they require to perform these roles (role-based access controls)

• Maintain access audit logs of entities accessing data in our systems

• Maintain safe retention/storage of datasets in authorised cloud systems

• Conduct vetting of contractual agreements with third-party vendors/implementing agencies for data access and processing functions

6. WHY AND HOW DO WE PROCESS, DISCLOSE, AND/OR SHARE THIS DATA?

We use this data to serve you with the best civic experience, such as providing grievance redressal mechanisms, efficient service delivery, creating dashboards of ULB activities, etc. Specifically:

• We process this data as necessary to provide you with the services you are requesting.

• We may process, disclose, or share certain metadata, as well as aggregated and anonymised data, in order to assess and improve the status of such service delivery over time.

• We may disclose or share this data to/with employees and/or contractors of the urban local body, state government, or other government agencies, or service providers, whose role requires them to view or use this information in order to perform their official duties, including providing you the service(s) you are requesting.

• Resolving any disputes that may arise with respect to the transactions/deals that you may conduct using the app/website.

• Monitoring user activity and preferences as evidenced by user’s activity on the app to provide a better experience in future.

• Detecting, investigating and preventing activities that may violate our policies or that may be illegal or unlawful.

• Conducting research or analysis of the user preferences and demographics as statistical data and not as individual data.

• We may disclose or share this data in order to comply with the law or any legal process, including when required in judicial, arbitral, or administrative proceedings.

• Payments made through the <PROGRAM NAME> App/website are processed via secure payment gateways.

We will not process, disclose, or share your data except as described in this policy or as otherwise authorized by you.

7. HOW DO WE PROTECT PERSONALLY IDENTIFIABLE INFORMATION (PII)?

By default, we display PII in a masked format. Persons with the appropriate authorisation can request for this data to be unmasked. We log each such request, thus creating a non-repudiable and auditable trail of each such access to PD[2].

8. CAN THIS POLICY BE CHANGED?

Yes, this policy is subject to change at any time and without notice. This page will be updated with any such modified policy, and such changes will not be deemed to take effect until and unless they are shown on this page. You are reading the current version of the policy.

9. YOUR CONSENT TO DATA COLLECTION, PROCESSING, DISCLOSURE, AND/OR SHARING.

By using this service, you confirm that you have read, understood, and accepted this Policy, and that we may collect, process, disclose, and/or share your data as described in this Policy.

10. GRIEVANCES

In case of any grievances, you may send your complaints for redressal over the Grievance Portal available at <LINK TO GRIEVANCE PORTAL / MECHANISM>.

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1. Once any data-related legislation is introduced, a formal/detailed Privacy Policy can be drafted and linked here. ↑

2. As above, this can be detailed in the Full Privacy Policy. ↑